NCS000421_High Point Draft SWMP v2 DEQ Comment Letter_20210621

ROY COOPER
Governor
lktv
JOHN NICHOLSONInterim
Secretary
BRIAN WRENN
NORTH CAROLINA
Director
Environmental Quality
June 21, 2021
VIA EMAIL ONLY
RETURN RECEIPT REQUESTED
City of High Point
Attn: Randy McCaslin, Interim City Manager
randy.mccaslinkhighpointnc. gov
211 S. Hamilton
High Point, NC 27261
Subject: COMMENTS ON DRAFT SWMP v1 (NOD-2019-PC-0205)
City of High Point
NPDES MS4 Permit No. NCS000421
Guilford, Randolph, Davidson & Forsyth County
Dear Mr. McCaslin:
On August 19-20, 2019, the North Carolina Department of Environmental Quality (DEQ) audited the
City of High Point (City) for compliance with the subject NPDES MS4 permit. As a result, a Notice of
Deficiency (NOD) was issued to the Town on January 27, 2021. The NOD defined specific document
submittals and deadlines, including the required Draft SWMP submittal (version 2) received on March 1,
2021.
Staff have reviewed the submitted Draft SWMP v2 and are providing the following specific comments,
which are also incorporated into the attached mark-up version of the Draft SWMP (in track changes
format). Please address all comments and submit a signed Draft Final SWMP and permit renewal
application form within thirty (30) calendar days of receipt of this letter. Upon receipt, if the
comments have been adequately addressed, the Draft Final SWMP will be sent to notice for public
comments and subsequent permit issuance.
Comments:
1. Please note that the attached Draft SWMP mark-up document is provided in the file that the city
provided and has numerous formatting issues. It is assumed that these issues are due to
converting a pdf file to a Word file. Please QA/QC the Final Draft SWMP document to ensure
that formatting errors, if any, in the submitted file(s) are addressed.
2. Incorporate the standard 2021 SWMP template updates, available on the MS4 web page and
included in the attached mark-up of the submitted Draft SWMP. These updates are generally
denoted in the attached mark-up document by green highlighting, which should be unhighlighted
prior to submittal.
3. Add "DRAFT FINAL SWMP" watermark and/or footer title.
4. Update document date on cover page and in footer.
E Q North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 11612 Mail Service Center I Raleigh, North Carolina 27699-1612
Moan-icnaounu �
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5. The brief program descriptions provided in the submitted self -audit provides an excellent
introduction to the city's stormwater program. Consider incorporating this information in the
SWMP to provide a brief introductory paragraph prior to each BMP table.
6. Paragraph 3.2: Clarify "the Point."
7. BMP 1.C.1: Remove permit year 5 from the annual assessment process. A detailed compliance
audit of the program will be performed in year 5.
8. BMP 3.1.13: Add "upon request" and change reporting metric to just the number of students
reached.
9. BMP 3.C.: Change reporting metric to just the number of participants.
10. BMP 4: Add, ".... Educational topics will vary and may include general stormwater awareness
and the pollutants/sources listed in Table 12 above for the general public target audience (litter,
pet waste, FOG, nutrients, illicit discharges, illegal dumping)"; delete "date of event" from
reporting metrics; change reporting metric for Measurable Goal (MG) 3 to "Number of events
held and number of interactions".
11. BMP 5: Remove "date and topic" from reporting metrics and make the following changes to
ensure that Table 12 items are addressed over the term of the permit:
a. MG 1: "... stormwater eeneepts information and pet waste"
b. MG 3: "...flyer for litter/household wastes..."
c. MG 4: "...and fats, oil and grease (FOG)."
12. BMP 6: Remove "..and update inventory" from reporting metrics.
13. BMP 8: Change frequency to Annually, delete "date" from reporting metrics. Change MG to,
"...Sekedttle Post at least three stormwater specific informational social media posts per year."
14. BMP 9: Change frequency to Annually, delete "date" and add topic(s) displayed to reporting
metrics. Change MG to, "....carts, etc.) to display an informational stormwater messag;e."
15. BMP 10: Change BMP to, "...services offered, educational brochures/fliers and
reporting/contact information." Change reporting metric to Yes/No/Status.
16. BMP 12: Update to "See BMP 11".
17. BMP 13: Delete and renumber all following BMPs. Social media is applicable to public
education and outreach, but it does not fulfill public participation needs since it does not
measurably provide something to the city.
18. BMP 15: Change frequency from Continuously to Annually; MG 2 add Adopt -a -Stream and
make reporting metric just number of new groups.
19. BMP 16: Change frequency to annually and make the following changes:
a. MG 1: "...new storm drain marking; volunteer group..." and change reporting metric to
Yes/No/Status.
b. Add MG 2: Coordinate storm drain marking and track marked drains, Annually Permit
Years 1-5, and report number of storm drains marked, number of participants.
20. BMP 17: Change Stormwater to Storm Sewer. Add MG 2:
a. Maintain storm sewer system map including stormwater conveyances, flow direction,
major outfalls and surface waters.
b. Continuously, Permit Years 1-5
D North Carolina Department of Environmental Quality Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
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NORTH CAROLINA
Oepartmeru of Environmeirtal Quad /`� 919.707.9200

c. Yes/No/Status and total number of outfalls mapped
21. BMP 25: Change reporting metric to just Yes/No/Status and Number trained.
22. BMP 29: Change to "See BMP 11" rather than duplicate the MG and reporting.
23. BMP 30: Delete "language" from the BMP description.
24. BMP 31: Add MG 2:
a. Develop and distribute informational Fact Sheet at pre -construction conferences
b. Continuously, Permit Years 1-5
c. Yes/No/Status and total number of Fact Sheets distributed
25. Permit Ref. 3.6.5(a): Delete template instructions in red italics.
26. Permit Ref. 3.6.6: Add a BMP for septic O&M education and outreach. Most MS4s distribute an
informational fact sheet to septic owners within their jurisdiction.
27. BMP 36: Change reporting metric to just Yes/No/Status and number trained.
28. BMP 37.D.2: Correct numbering and change reporting metric to just Yes/No/Status and number
trained
29. BMP 39.D.2: Add number of MS4 inspections performed.
30. BMP 39.13.3: Clarify this MG. Suggest changing it to "Maintain a prioritized Capital
Improvement Project list." And report number of Yes/No/Status, Number of CIPs on list and
number of CIPs completed.
31. BMP 40: Change to "See BMP 36" or describe what training will be provided.
32. BMP 41.D.2: Correct numbering and add total number of municipal SCMs inventoried.
33. BMP 41: Delete MG 3, this is a duplicate of MG 42.13.1.
34. BMP 42.D.1: Add number of certified staff to reporting metrics.
35. BMP 42.13.2: Change wording to "Conduct annual SCM inspections afe elonducted per the SCM
Inspection SOP." And change frequency to Annually.
36. BMP 42.D.3: Change reporting metric to number of SCMs maintained.
37. BMP 43.D.1: Add number of licensed staff to reporting metrics.
38. BMP 43.D.2: Change reporting metrics to Yes/No/Status and number trained.
39. BMP 44.D.2: Describe training to be provided or reference another BMP. Add number of
industrial stormwater permitted facilities to reporting metrics.
40. BMP 44.D.3: Add number of industrial facility inspections to reporting metrics.
41. BMP 44.D.4: Change reporting metrics to Yes/No/Status and number trained.
42. BMP 45.D.1: Add number of inspections performed to reporting metrics.
43. BMP 45.D.2: Add number of follow-up inspections performed to reporting metrics.
The required revised Draft Final SWMP and permit application submittal must include both a hard copy
and a pdf electronic copy. The hard copies must include an original "wet" signature by the Town's
ranking elected official or designated staff member in compliance with Part IV, Paragraph G of the
NORTH CAROLINAD_E Q��
Oepartmeru of Environmerrtal Quay
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center 1 Raleigh, North Carolina 27699-1612
919.707.9200

current MS4 Permit. Please also submit a Microsoft Word Track Changes version identifying all changes
made to the Draft SWMP v2 to address these comments.
Please submit the required signed Draft Final SWAP and permit renewal application to:
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612
ieanette.powell(ae,ncdenr.gov
Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
Jeanette.Powellkncdenr. gov.
Sincerely,
Jeanette Powell
MS4 Program Coordinator
Cc via email:
terry.houk(cDhiahgointnc.gov
robby.stone(cDhighgointnc.gov
Annette Lucas, DEMLR Stormwater Program Supervisor
Tamera Eplin, Winston Salem Regional Office
DEMLR NPDES MS4 Permit Laserfiche File
D North Carolina Department of Environmental Quality Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
EQ�j
NORTH CAROLINA
Oepartmeru of Environmerrtal Quad /`� 919.707.9200